On August 11 the FCC published a proposed rule seeking to ban the import, marketing and sale of of drones equipped with technologies the FCC describes as “weapons of war”. Many in the drone industry, including me, are pushing back, describing the definitions as overly broad. The proposed rule would ban any foreign made drone equipped with thermal imaging systems and LIDAR. These Technologies are commonly used by emergency responders like police, fire departments and emergency government. If this rule is passed it would eliminate valuable tools that first responders rely upon to save lives. The deadline for the public to submit their comments ends today September 2. I submitted my comments to this proposed rule.

You can read them below. If you want to make your voice heard there’s still time to act. For a brief explanation of the rule making process and links to submit your own comments, visit the Drone Advocacy Alliance.

BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554

In the Matter of

Prohibiting the Importation and Marketing of Certain Foreign-Produced
Military-Grade Uncrewed Aircraft Systems (UAS) and UAS Critical Components

PS Docket No. 26-189
Public Notice DA 26-758

COMMENTS OF WILLIAM BONGLE
TITLETOWN DRONES LLC

I. Statement of Interest

My name is William Bongle. I am a retired police captain and the owner of Titletown Drones LLC, a small U.S. business that sells and supports unmanned aircraft systems. A substantial portion of my customers are police departments, fire departments, emergency management organizations, and other government and public safety agencies.

I support reasonable measures to protect the United States from genuine national security threats associated with unmanned aircraft and foreign supply chains. My concern is that the categories proposed in PS Docket No. 26-189 are so broad that they would treat common civilian and public safety technologies as “military-grade” based primarily on the presence of particular sensors or capabilities, rather than on the aircraft’s actual design, intended use, or demonstrated risk.

The result could be the loss of affordable, reliable, and proven tools used every day for search and rescue, firefighting, emergency response, mapping, inspection, agriculture, and ordinary civilian flight. I urge the Commission to adopt a narrower, risk-based approach that protects national security without unnecessarily reducing public safety capability.

II. Thermal Imaging Is a Public Safety Tool, Not Inherently a Military Capability

Thermal imaging has become an essential public safety capability. The agencies I serve use thermal-equipped drones to locate missing persons, search wooded and difficult terrain, support nighttime operations, locate fire hot spots, evaluate structures, assist disaster response, and provide situational awareness without unnecessarily exposing responders to danger.

A technology should not be classified as military-grade merely because the military also uses it. Thermal cameras, GPS, night vision, radios, binoculars, and many other technologies have both civilian and military applications. The appropriate inquiry should be whether an aircraft is designed or configured for a military purpose or presents a demonstrable national security risk—not simply whether it contains a thermal sensor.

For a small police or fire agency, a thermal drone can provide an aerial capability that would otherwise require resources far beyond its budget. Removing affordable thermal systems from the market therefore has a direct operational consequence: some agencies will have less capability to find people, assess emergencies, and protect responders.

III. LiDAR Used for Obstacle Avoidance Should Not Be Labeled “Military-Grade”

The proposed treatment of LiDAR creates a similar problem. LiDAR is used for mapping, surveying, inspection, navigation, and increasingly for obstacle detection and collision avoidance on small civilian drones.

Consumer aircraft such as the DJI Air 3S, DJI Mini 5 Pro, and DJI Neo 2 illustrate why the presence of LiDAR alone is an unsuitable test for determining whether an aircraft is military-grade. On aircraft of this type, LiDAR is used to help the aircraft perceive nearby obstacles and operate more safely, including in difficult lighting conditions.

In this context, LiDAR is a safety technology. Federal policy should encourage technologies that reduce collisions with trees, structures, wires, and other obstacles. I urge the Commission to expressly distinguish ordinary obstacle-avoidance, navigation, mapping, and surveying sensors from specialized systems genuinely designed for military purposes.

IV. Domestic Alternatives Must Be Evaluated for Affordability, Capability, and Total Cost of Ownership

I would gladly offer American-manufactured drones to my customers if comparable products were available at prices those customers could reasonably afford. The problem is not an unwillingness to buy American. The problem is that many domestic alternatives currently occupy a substantially different price point and purchasing model.

One of the principal U.S.-manufactured aircraft marketed to public safety is the Skydio X10. In the public safety market, X10 configurations commonly fall in roughly the $15,000 to $25,000 range depending on configuration and associated products and services. By comparison, actual quotations from my business immediately before the recently announced UAS tariffs demonstrate the price at which capable foreign-manufactured thermal systems have been available to American customers.

These are not hypothetical internet prices. They are actual 2026 customer quotations from my small business. They show that, before the new tariff structure changes the market, sophisticated thermal UAS capability was available in approximately the $6,000 to $9,000 range.

Availability is not the same as affordability. The existence of a domestically manufactured aircraft with a thermal camera does not make it an economically equivalent substitute. For a small police department, sheriff’s office, municipal or volunteer fire department, or emergency management agency, moving from an approximately $6,000–$9,000 acquisition to a $15,000–$25,000 acquisition can determine whether the agency has the capability at all.

The Commission should also evaluate total cost of ownership, not merely initial purchase price. Some domestic UAS ecosystems offer advanced capabilities through recurring software, cloud storage, fleet management, connectivity, and service subscriptions. Those services may be valuable for some organizations, but the purchasing model can be unattractive to smaller agencies.

V. Recurring Subscription Costs Are a Significant Issue for Small Agencies

My experience as a police administrator is directly relevant to this issue. Smaller agencies are often reluctant to assume new annual financial commitments. A chief may be able to obtain a one-time appropriation, grant, donation, or other funding source to purchase equipment. That does not mean the agency will receive an additional appropriation every year to maintain subscriptions associated with that equipment.

Recurring expenses must compete annually with personnel, vehicles, radios, body-worn cameras, protective equipment, training, fuel, and other essential public safety costs. An agency that can secure a one-time grant for a drone may therefore prefer a system it can purchase, train on, maintain, and operate for several years without creating a substantial recurring budget obligation.

The Commission should ask whether a domestic alternative provides reasonably comparable capability, reliability, and total cost of ownership and whether it is realistically sustainable for a small public safety organization. If the answer is no, the alternative is not functionally equivalent merely because it exists.

VI. The Likely Result for Some Agencies Is No Purchase at All

A large federal agency or major metropolitan department may be able to absorb a substantially higher acquisition cost. Many small agencies cannot. If an affordable foreign-manufactured thermal UAS disappears from the market, the practical choice may not be between a foreign aircraft and an American aircraft. The practical choice may be between the affordable aircraft and no aircraft at all.

That outcome would fall disproportionately on small and rural communities. Those agencies may benefit the most from UAS because a drone allows a small number of responders to search a large area, obtain an aerial perspective, or deploy a thermal camera without the extraordinary cost of a manned aviation program.

Affordable UAS technology has democratized aerial public safety capability. The Commission should be cautious about adopting a policy that unintentionally reverses that progress.

VII. Recently Announced Tariffs Add to the Cumulative Economic Pressure

The Commission should also recognize, without allowing the issue to distract from this proceeding, that these proposed restrictions are not occurring in isolation. On August 13, 2026, the President announced Section 232 tariffs on imported UAS. The proclamation provides for a 100 percent ad valorem duty on covered imported UAS that integrate thermal imagers, effective September 3, 2026, subject to specified exceptions and preferential treatment.

Those tariffs will change future market pricing, which is why the quotations above are presented as evidence of the market immediately before the new tariff structure. The larger point is the cumulative effect: federal policy is already applying substantial economic pressure intended to encourage domestic UAS production. Additional FCC restrictions could remove future choices entirely before capable and affordable domestic substitutes are broadly available.

Regulation can change the relative price of competing products, but it does not increase the purchasing power of a small public safety agency. The Commission should consider whether existing industrial-policy measures should be given an opportunity to increase domestic capacity and competition before additional restrictions eliminate products on which public safety agencies currently depend.

VIII. Target Demonstrable Security Risks Rather Than Broad Dual-Use Categories

If foreign-produced UAS present specific cybersecurity, data-security, communications, or supply-chain risks, I support objective standards that address those risks. Manufacturers should be able to demonstrate compliance with appropriate requirements concerning data transmission, storage, network security, firmware integrity, and supply-chain security.

A risk-based approach would be more precise than assuming that every foreign-produced aircraft containing thermal imaging or LiDAR presents the same threat. It would also allow the government to protect legitimate national security interests without unnecessarily eliminating useful civilian technologies.

IX. Remote ID Shows the Value of Targeted Accountability Measures

The federal government has already required substantial investment by manufacturers and operators in Remote Identification for the stated purpose of improving accountability in the National Airspace System. That experience demonstrates that targeted technical requirements can be adopted when the government identifies a specific accountability or security concern.

Remote ID is principally an FAA program, not an FCC equipment-authorization program, and I do not suggest that it resolves every security concern raised in this proceeding. I do believe, however, that federal UAS policy should make meaningful use of accountability mechanisms already imposed on operators and should favor targeted technical safeguards where they can address an identified risk before resorting to broad categorical prohibitions. 

X. Adverse Impact on American Small Businesses

The proposed restrictions would also harm American small businesses such as mine. Small dealers do more than sell an aircraft in a box. We help public safety agencies select equipment, understand capabilities and limitations, train personnel, troubleshoot problems, maintain equipment, and build effective programs.

I entered this market in good faith and invested in inventory, customer relationships, training, technical knowledge, and support infrastructure around products legally authorized for sale in the United States. Abruptly restricting continued importation and marketing of broad categories of previously authorized products disrupts inventory, distribution relationships, customer support, future sales, and the viability of small American businesses.

Small American retailers, instructors, and service providers should not become collateral damage to strengthen domestic manufacturing. My business has already suffered significant financial impact due to the volatility of the drone market and eroded consumer confidence. This is the direct result of confusing and sometimes conflicting information. If this rule is passed as proposed, things will only get worse.  The tools and equipment my customers rely on will be unavailable with no comparable domestic substitute.  To make an analogy, it’s as if I were a cellular phone dealer and the government decided I could no longer offer my customers Apple or Android phones.  We need a transition period for domestic manufacturing to catch up. When that happens, I’ll be a strong advocate for “Made in America” drones.  I can’t do that if I am no longer in business. 

XI. Requested Action

I respectfully urge the Commission to narrow the proposed approach and:

1. Remove thermal imaging capability alone as a basis for treating a UAS as military-grade, or establish clear exemptions for legitimate public safety, emergency response, commercial, agricultural, and other civilian uses.
2. Remove LiDAR capability alone as a basis for treating a UAS as military-grade and expressly exclude LiDAR and ranging sensors used for obstacle avoidance, navigation, mapping, surveying, inspection, and similar civilian functions.
3. Distinguish aircraft designed or configured for military operations from civilian aircraft incorporating dual-use technologies.
4. Evaluate domestic alternatives based on comparable capability, reliability, acquisition cost, and total cost of ownership—not simply on whether an alternative product exists.
5. Give particular consideration to the disproportionate impact on small and rural police, fire, emergency management, and other public safety organizations.
6. Use objective cybersecurity, data-security, and supply-chain standards where those measures can directly address the identified risk.
7. Provide meaningful transition periods and appropriate public safety safeguards where equivalent and economically viable alternatives are not reasonably available.
8. Consider the cumulative impact of the proposed restrictions together with recently announced UAS tariffs and other federal actions affecting the same market.
9. Consider the economic impact on U.S. small businesses that lawfully sell, integrate, train on, maintain, and support these systems.

XII. Conclusion

I spent my career in law enforcement, and I understand that protecting the country sometimes requires restrictions and difficult decisions. National security concerns surrounding foreign-manufactured UAS deserve serious consideration. But good public safety policy also requires careful consideration of unintended consequences.

A drone used to locate a missing child, an elderly person with dementia, or a lost hunter is a public safety tool. A thermal camera used by firefighters to locate hot spots is a public safety tool. A LiDAR sensor used to prevent a small civilian drone from colliding with an obstacle is a safety feature—not, by itself, a weapon of war.

I want a strong American UAS manufacturing industry, and I would welcome American products that provide the capability, reliability, and affordability my customers need. But public safety agencies should not be required to surrender proven operational capability while waiting for the domestic market to reach that point.

The objective should be both a stronger domestic UAS industry and a safer America. Those goals do not have to be mutually exclusive. I respectfully ask the Commission to narrow the proposed categories, focus restrictions on demonstrable risks and genuinely military capabilities, and preserve access to affordable technologies that help American first responders protect lives.

Respectfully submitted,
William Bongle
Retired Police Captain
Certified Remote Pilot
Titletown Drones LLC
Suamico, Wisconsin
https://titletowndrones.com

Source Notes and Supporting Market Evidence

FCC proceeding: Federal Register, 91 FR 48870-48874 (Aug. 3, 2026), PS Docket No. 26-189, DA 26-758. The notice seeks comment on prohibiting continued importation and marketing of certain previously authorized foreign-produced UAS and components and sets a Sept. 2, 2026 comment deadline.
https://www.govinfo.gov/content/pkg/FR-2026-08-03/pdf/FR-2026-08-03.pdf

UAS tariffs: Presidential Proclamation, Aug. 13, 2026. It establishes a 100% ad valorem duty on covered imported UAS integrating thermal imagers, effective Sept. 3, 2026, subject to stated exceptions and preferential treatment.
https://www.whitehouse.gov/presidential-actions/2026/08/adjusting-imports-of-unmanned-aircraft-systems-and-unmanned-aircraft-systems-components-into-the-united-states/